Thank you for your letter dated May 16, requesting an interpretation
regarding the removal of a recorded case from your 1993 OSHA Log. Your
letter was transferred to my office from the OSHA Office of Information and
Consumer Affairs. The OSHA Office of Statistics is responsible for the
administration of the injury and illness recordkeeping system nationwide.
Whenever possible, I will refer to the Recordkeeping Guidelines for
Occupational Injuries and Illnesses by stating the appropriate page and
Q&A numbers.

OSHA recordkeeping requirements and definitions differ from those
established under various State workers' compensation laws (page 27).
Workers' compensation determinations do not impact the recordability of cases
under OSHA recordkeeping requirements (Q&A B-1 on page 26 and Q&A G-2 on page
46). Conversely, OSHA recordkeeping determinations should not affect the
employer obligations under State workers' compensation systems (page 45,
section G ). Some cases may be covered by workers' compensation but are not
recordable; other cases may be OSHA recordable but are not covered by
workers' compensation. Workers' compensation criteria should not be
substituted for OSHA definitions in determining whether or not a case should
be recorded under the OSHA system.

Work relationship is established under the OSHA recordkeeping system when an
injury or illness results from an event or exposure in the work environment.
The general rule is that all injuries and illnesses which result from events
or exposures on the employer's premises are presumed to be work related.
Furthermore, if it seems likely that an event or exposure in the work
environment either caused or contributed to the case, the case is considered
work related. It is sufficient for an exposure to only be a contributing
and/or aggravating factor to establish work relationship for OSHA
recordkeeping purposes. (Q&A C-7 on page 34, Q&A B-17 on page 32, and Q&A E-6
on page 40)

I hope you find this information useful. If you have any further questions,
please contact my staff at Area Code (202) 219-6463.

Sincerely,

Stephen A. Newell
Director
OSHA Office of Statistics

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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